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RESPONSE TO WRITTEN COMMENTS -24_ City Of Stockton-Regional Wastewater Control Facility NPDES No. CA0079138 26 April 2002 Board Meeting Stockton Comment No. VIII.: The Findings need to reference the bibliography as the basis upon which the order was developed. In addition, the bibliography needs to be expanded to include additional reports and information provided by the City in support of the permit action. In addition to these documents, the complete record of the Health Risk Assessment(e.g., study approval, meeting, - correspondence, and reports) and the City's thermal plan compliance evaluation needs to be included in the record. RWQCB Response: All documents included in the case file, i.e. discharger monitoring reports, correspondence, etc., are considered part of the record. The documents requested to be part of the Bibliography are included in the case file, and as such are part of the record. It is impracticable to list every document in the Bibliography. IX. Reservation of Rights Stockton Comment No. IX: The City reserves the right to submit additional comments and information as necessary and appropriate to address issues with the proposed pen-nit. Finally, the City incorporates by reference the evidence and arguments of the POTW parties in the recent City of Vacaville appeal to the SWRCB. RWQCB Response: The City was provided an opportunity to submit comments on the tentative permit during a specified comment period. Any comments, information, or evidence submitted after the comment date will not be accepted into the record except as allowed in the applicable regulations (Title 23 California Code of Regulations, Section 647 et seq. The Regional Board will not include in the record for the matter concerning the City of Stockton's waste discharge requirements, the record, evidence, arguments, or other information included in the record of the City of Vacaville matter. This matter is an adjudicatory proceeding that applies specifically to the City of Stockton. The record related to another matter involving another discharger in a different water body is not relevant. Attachment II Additional Comments on Disinfection Requirements Stockton Comment No. Att. II.a: Based on the information provided, it appears the Regional Board did not evaluate the level of risk associated with the threat of any specific pathogen in the City's discharge to public health or the beneficial uses of receiving waters. There is significant dilution available under all flow conditions, and the median condition approached the 20:1 dilution factor considered by DHS as the dilution level which justifies a 23 MPN (thirty-day median) coliform limitation and no turbidity requirement. Thus, it is apparent the basis suggested for imposing a stringent coliform requirement in order to protect public health is incorrect, inconsistent with prior Board determinations, and fails to consider all of the relevant information.